Hacks When Writing Deposition Summaries


The deposition summary is a vital part of the trial process. It helps you fully understand the case and your client’s perspective on the events.

Taking down a deposition summary is hard work as it requires you to pay attention to every detail, especially when it comes to cross-examination.

You cannot afford to miss out on any important detail that can impact the trial proceedings.

As a paralegal, you need to be careful about how you take down the deposition summary. It should be accurate, organized and complete with all key details.

To help you avoid mistakes when taking down a deposition summary, here are some hacks for writing deposition summaries:

Prepare for the Deposition

When writing a deposition summary, you need to be prepared for everything before it begins. It will act as your reference point for taking down notes during the proceedings. This preparation includes:

  • Familiarizing yourself with the deposition notice
  • Getting access to client files and evidence from previous depositions
  • Having witness information ready (including contact info)
  • Having some background knowledge about the parties involved in the case

Get the Details of Your Client’s Case Down First

Before you write any deposition summaries, make sure you know the details of your case first.

Start by writing a summary of the accident or incident in question. List out all of the parties involved and their relationships with one another.

For instance, if you’re defending someone in a car accident case, list out their name, address and contact information; include their insurance company with its data as well.

Be Objective and Concise

The purpose of writing a summary of your deposition is so that you can review everything that happened in court.

And to assess whether or not your client’s side had presented its evidence strongly enough.

This means that while you summarize the event, you have to make sure that it is as objective as possible and without any biases whatsoever.

Use a Template

If this is your first time writing a deposition summary, use a template as a guide.

You don’t need to memorize the template, but it can be helpful to have it handy when you’re feeling anxious and intimidated about creating your own summary from scratch.

Bottom Line

Even the most intricate litigation cases are often boiled down in a deposition summary through multiple depositions of each party.

Writing the summary for a case can be daunting and time-consuming.

Due to this, each summation writer needs to follow a set of custom checks that will help them write the two- or three-page long document correctly.

You should write the summation precisely but with as little jargon as possible to save room on the document.


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